Reference EASA, Notice of Proposed Amendment (NPA) 2013-19 (Part-147 — IR, AMCs & GM Part-66 — IR, AMCs & GM) “Concept Paper”.
SMS Requirements related to an EASA Part 147 Organisation
The need to demonstrate compliance with ICAO Annex 19 (long overdue) is a major driver regarding the implementation of Safety Management System (SMS) within an EASA Part 147 & Part 66 Organisation.
NPA 2013-19 proposes to amend Annexes III ‘Part-66’ and IV ‘Part-147’ to Commission Regulation (EC) No 2042/2003 (now it is 1321/2014 to implement SMS and to support the implementation of SSP/EASP.
It relates to the ongoing EASp (European Aviation Safety Program).
The existing rule structure remains unchanged. (a) Changes to Part-147 Section A (technical requirements) mainly focus on the creation of streamlined, consolidated management system requirements that, while built upon existing quality systems, improve consistency in organisation approvals, and introduce additional requirements related to hazard identification, risk evaluation, and effective risk mitigation.
The new requirements ensure compatibility with existing management systems, and facilitate systems integration for organisations holding more than one certificate.
The proposed management system framework, together with the Essential Requirements of the Basic Regulation, address elements of the ICAO SMS framework (as per ICAO Annex 19 ‘Safety Management’) while ensuring proportionality and flexibility.
Changes to Part-147 Section B (authority requirements) take due account of the critical elements of a State’s safety oversight system as promoted by ICAO, support the implementation of SSPs, and serve the standardisation objective set out in the Basic Regulation.
This aims at streamlining procedures for oversight, and introduces new management system requirements for competent authorities to increase efficiency and support the establishment of a comprehensive aviation safety management system at EU level, encompassing EU and Member States’ responsibilities for safety management.
Changes to Part-66 are limited to introducing management system requirements in Section B ‘Procedures for the competent authority’ and updating the training syllabus in modules 9A and 9B with new SMS related elements.
Concerning the Need for mandatory reporting within an EASA 147 Organisation
Article 4 of Regulation (EU) No. 376/2014 defines the persons and organisations obliged to report occurrences under the “mandatory reporting system”. Personnel working at/for organisations approved in accordance with EASA Part 147 are not listed in paragraph 6 of article 4, therefore such organisations are not required to implement either mandatory or voluntary reporting systems.
This does not “off course” prevent any organisation or person involved in aviation activities, including maintenance training activities, to report any safety occurrence or other safety information they consider relevant.
Typically a Part- 147 approved training organisation having implemented an Safety Management System (SMS) would also have an internal reporting system and will be able to submit reports on a voluntary basis.
An online service developed by the EC allows organisations and individuals to report aviation safety occurrences to aviation authorities.
For additional details please see www.sassofia.com or email: office@sassofia.com
